To the Secretary, members of the Development Assessment Commission and any interested parties,

Please accept my personal submission in response to development number 010/V030/15 – a proposal for the development of an “in sea marine aquarium in Encounter Bay” made by Oceanic Victor Pty Ltd.

I am providing this submission in two parts. The first is a response to newly available information contained in the development application public notice. The second part of my submission is a copy of a submission I made earlier this year to PIRSA related to the same project. Many of the points I raised in my earlier submission have not been acknowledged or referred to in the Oceanic Victor Pty Ltd Marine Pilot Lease and License Application – Submission response document prepared by PIRSA Fisheries & Aquaculture in September 2015.

1 – General criticism

It is my belief that the proponents of this development, whose application to the DAC has been prepared by Donna Ferretti and Associates Pty Ltd, have deliberately avoided mentioning the principle attraction at the proposed facility: the Southern bluefin tuna, Thunnus maccoyi. This is significant, as directors of the company Oceanic Victor Pty Ltd have commercial interests in the tuna ranching and harvesting industry through directorships and/or employment at Tony’s Tuna International. It is also significant as tuna are listed by the IUCN Red List as a Critically Endangered species. To propose a tourism enterprise, the key attraction of which has such high international conservation significance, and then not mention it in the development application to the DAC, is in my opinion both disingenuous and manipulative. The subjects to be held in the aquarium are described ambiguously as “a range of native fish species” where the PIRSA Submission response document clearly specifies that up to five tonnes of Southern bluefin tuna are to be held, and up to 0.5 tonnes of other species. This operation’s success relies on the keeping of SBT, which is consistent with the wider commercial interests of its proponents, and the nature of the infrastructure proposed to be deployed in Encounter Bay.

2 – Description of the Proposed Development

The application states that “two 1500 litre flow through touch tanks” will operate at the facility. It refers to “proposed low fish stocking rates” yet provides no detail regarding the species and stocking density of these touch tanks. Each of these tanks is its own enclosed environment, and the keeping of certain numbers or indeed certain species given the shallowness of the tanks and their exposure to ultraviolet light are aspects that in my opinion should be detailed and made available for public consideration. I previously requested that a mortality register be kept by the facility, to provide evidence that the facility was doing its best to keep any captive marine species in a healthy condition, including but not limited to those organisms kept in touch tanks.

I am concerned that the application states that the aquarium will be stocked with fish in Port Lincoln before it is towed into place in Encounter Bay. It is plausible that some of the species chosen for display would come from populations which are range limited, and represent genetically distinct populations which are entirely separate from populations found in Encounter Bay. While I can see how towing Southern bluefin tuna over from Port Lincoln would be necessary for the proponents, I would recommend that the DAC applies a condition that all other species to be displayed by Oceanic Victor are obtained from the Encounter Bay area, in order to avoid interfering with the genetic make-up of Encounter Bay populations. Another unintended consequence of not applying this condition could be the introduction of parasites or diseases from one population of a species to another.

3 – Location of the Proposed Development

The application acknowledges that the proposal is located within a Habitat Protect Zone of the Encounter Marine Park and claims that marine park management allows “activities that will not cause environmental harm.” PIRSA’s own documentation suggests that harm is anticipated, but that fallow periods, and relocating the seacage within the lease area will allow damaged habitat to recover. Is this consistent with the objectives of a Habitat Protection Zone, within a State managed marine park?

It goes on to state that “PIRSA is supportive of the proposed development and, by requiring only five conditions to be met as part of its environmental assessment, is confident that the tourism operation poses no threat to marine habitats.” It would be appropriate, given that the proponent has acknowledged that these conditions have been established, to make them available for public consideration. What are these five conditions the proponent must meet?

The application also states that “no contaminating substances or materials that may pollute, contaminate or degrade the site or adjacent land and waters are allowed on the lease area.” This condition is ironic given that the proposal’s main attraction, the keeping of Southern bluefin tuna, produces and introduces such contaminating substances. Through feed and faeces, SBT ranching contributes contaminating substances directly into the lease area. The known implications of this contamination are further evidenced by the requirement that the sea cage be moved every twelve months in order to facilitate recovery of habitat below the sea cage, caused by cover and contamination.

4 – Operational Procedures

The development application states that its operational plan has been developed “in consultation with PIRSA and other marine experts” who remain unnamed. I would argue that it would be appropriate in the public interest for these persons and their involvement in the project to be specified and for this operational plan to be disclosed to the public, rather than the selective disclosure of “key features”. For example, one “key feature” states that “the marine site will be accessed up to five times daily (weather permitting) during the tourist season and once daily outside the tourist season.” This raises more questions than it answers.

The term “tourist season” should be clearly defined as this will have implications for the feeding regime, which will change across the seasons. Will stocking density also change during the off-season? I wish to know whether non-SBT species will be kept on the premises at all during the off-season. It is my opinion that they should not be held during periods in which there is no tourist demand for the attraction, and that any captive non-SBT species should be sourced locally (in the Encounter Bay area) and kept for a limited time, after which they are returned to the sea in good health. I would also like to understand the seasonality of nutrient loading and how this relates to the feeding regime given that feeding frequency will change from up to five times a day to once a day in and out of “tourist season”. Will the nutritional requirements of southern bluefin tuna be met with such a change? If so, can the proponent demonstrate how, given the high conservation status of the species? I would also like to know how the dietary requirements of non-SBT species will be met (some of which are likely to be herbivorous or eat molluscs) and if a holding time for some species is to be specified, after which specimens can be returned to the sea in good health- rather than retaining animals in touch tanks, potentially without feeding them, until they die.

In short, without seeing an operational plan for the facility, and no commitment by the proponent to keep a mortality register (a recommendation I made in my prior submission to PIRSA) that citizens cannot be assured that the captive non-SBT species’ health and welfare is being duly considered.

5 – Assessment

The Development Application claims that PIRSA’s assessment report “attests to the ecological integrity and sustainability of the proposed development… particularly in relation to water quality, seafloor health, ecosystems and biodiversity.” While it claims that it will “avoid any adverse impacts on wildlife in the locality” the only way to guarantee such an outcome is for the proposal to not be approved. I am not advocating for the dismissal of this application- but I am advocating that the proponents fully disclose their plans, their potential conflicts of interest, their operational procedures with respect to maintaining animal health, and their response plans in the event of interactions with threatened or protected species.

Such disclosure should also include a statement by the proponents as to whether they are likely to be beneficiaries of the proposal to establish a cruise ship anchorage which overlaps Oceanic Victor’s lease area.

I am also directly asking the question: do the directors or management of Oceanic Victor have any direct or indirect commercial interests in the potential establishment of commercial tuna ranching operations in any future lease areas in the Encounter Bay region? If they do not, it would help allay scepticism in the wider community immensely should such a statement be made.

I wish to request that the DAC also consider in full my prior submission made to PIRSA. Many matters raised therein are yet to be acknowledged or addressed to my satisfaction.

Your sincerely,

Dan Monceaux

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Dan Monceaux is a documentary filmmaker with a keen interest in marine biodoversity and conservation issues. He joined MLSSA in 2013 and served as Secretary from April-December 2014. Dan snorkels and has burning passions for underwater photography and citizen science.